Mario Kart
Animal Crossing
Breath of the Wild
Smash Ultimate

In that order, so 4.

I see Odyssey stalling at 25m and Sword and Sheild stalling at 22m.

Can't think of any other games that can even compete with these 6 outside BotW 2, Odyssey 2, or Gen 9 Pokémon, but even then all three of these games should make less than their predecessors, putting them below 30m.